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#tax-planning

Tax Planning

Strategic tax planning to minimize liability and maximize savings

FDII and Form 8993: How U.S. C Corporations Hit a 13.125% Effective Tax Rate on Foreign Sales

A working guide to the FDII (now FDDEI) deduction on Form 8993 — which U.S. C corporations qualify, how the Section 250 math drops the effective federal rate to 13.125% on foreign-derived income, the taxable income limitation, documentation the IRS expects, and how OBBBA simplifies the calculation starting in 2026 by removing the QBAI step and expense allocations.

Form 8886 Reportable Transactions: The 75 Percent Penalty Hiding in Your Tax Return

Form 8886 discloses reportable transactions to the IRS. Missing it triggers a Section 6707A penalty up to $200,000 per year for entities and keeps the assessment statute open indefinitely on listed transactions under Section 6501(c)(10). This guide breaks down the five categories, the penalty math, filing mechanics, and the foreign currency loss trap that catches accidental filers.

Generation-Skipping Transfer Tax in 2026: How Grandparents Move Wealth to Grandchildren Without Paying Estate Tax Twice

For 2026 the One Big Beautiful Bill Act sets the GST exemption at $15 million per person ($30 million per couple), with a flat 40 percent rate on transfers to skip persons; this guide covers skip-person rules, direct skips, taxable terminations, automatic versus elective exemption allocation, and how dynasty trusts achieve a zero inclusion ratio.

The IC-DISC: How Closely Held Exporters Cut Federal Tax on Export Profits to 23.8%

The IC-DISC is the only permanent federal tax incentive dedicated to U.S. exporters that is available to pass-through entities. It routes export commissions through a tax-exempt paper corporation and back out as qualified dividends, cutting the effective federal rate on export profits from roughly 40% to 23.8% for closely held manufacturers, distributors, software vendors, and engineering firms.

The IC-DISC Export Tax Strategy: How Closely-Held U.S. Exporters Cut Their Tax Rate on Foreign Sales to 20 Percent

An IC-DISC is a paper-only U.S. C corporation authorized by IRC Sections 991–997 that lets closely-held manufacturers, distributors, and growers convert qualifying export profit from ordinary income rates (up to 37%) into qualified dividend rates (20–23.8%), with typical setups producing $50,000+ in annual federal tax savings on $5M of qualifying export sales after Section 199A's 2026 sunset widened the rate spread.